Valero Refining Company - Texas - Executive Summary |
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1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Valero Refining Company - Texas, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 7 A description of our facility and use of substances regulated by EPA's RMP regulation 7 A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 7 An overview of our accidental release prevention programs 7 A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 7 An overview of our emergency response program 7 An overview of planned improvements a t the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 7 The certifications that EPA's RMP rule requires us to provide 7 The detailed information (called data elements) about our risk management program 2 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility is a petroleum refinery which produces gasoline, heating fuels, and streams for use as chemical feedstocks, using a variety of processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics - Chlorine in one ton cylinders Flammables - Miscellaneous flammable mixtures and pure component streams, stored in storage tanks and contained within process unit equipment The regulated substances are contained within the utlities areas of the plant (chlorine) and within the tank farm and si x other process units. Several other process units may contain regulated substances, but are either in mixtures that do not meet the definition of a flammable mixture, or are below the threshold quantity. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that may be posed to our employees, the public, and the environment by our use of these substances. 3 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals Valero has chosen to adopt the worst case scenario for a one ton container put forth in the EPA's Guidance for Waste Water Treatmen t Plants. That scenario results in an endpoint distance of 1.3 miles and has a potentially affected residential population of 9000 (from Landview III). Administrative controls are in place to prevent such a scenario, as well as proven equipment designs. Mitigation measures include fire water sprays to "knock down" a chlorine cloud should one occur, as well as trained responders for isolation and containment. Due to the meteorological conditions specified by EPA, the distance indicated is believed to be an overstatement of a ton container release. Alternative Release Scenario - Regulated Toxic Chemicals The alternative release scenario for chlorine was also put forth in the EPA's Guidance for Wastewater Treatment Plants. The scenario involves a release of 500 pounds per minute from a container, for which the impact radius is 0.37 miles. The potentially affected residential population (from Landview III census data) is 410. Worst-case Release Scenario - Regulated Flammable Chemicals The worst case flammable scenario chosen is a large tank in the tank farm area that contains up to 7,550,000 pounds of hydrocarbons, primarily pentanes. In this case, the endpoint distance (using EPA's OCA lookup tables) is 1.6 miles and the potentially affected residential population is 12,000. Mitigation measures include tank sprinklers, firewater monitors, and trained responders. The release of such a quantitiy of pentanes would not be expected to form the vapor cloud that is the EPA OCA Guidance basis, suggesting that the impact zone might be considerably less than stated. Alternative Release Scenario - Regulated Flammable Chemicals The alternative release scenario for flammables was calculated following the EPA's proposed OCA Guidance Reference Tables or Equations. The release chosen for modeling is a spill during load ing, resulting in a vapor cloud explosion having an impact zone of 0.13 miles. From Landview III, the potentially affected residential population is estimated at 70. We are using the above information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Additionally, the above information has been communicated to the public in community outreach programs. 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place include: OSHA PSM elements, including employee participation programs, process safety information, process hazard analyses, operating procedures and training, mechanical integrity programs with training, contractor programs, incident investigation, management of change, pre-startup safety reviews, compliance audits, and hot w ork and safe work programs. Additionally, Valero has implemented various safety programs addressing safe personnel protective clothing and equipment, hearing protection, safe entry and exit controls, impact protection and secondary containment controls, and a detailed analysis and adherence to generally accepted industry codes and standards. We have additionally adopted the Houston area contractors training program to assure that only qualified contractor personnel may enter the facility. Valero (and the prior refinery owner) has made every effort to assure compliance with OSHA PSM, dating back to 1992. Program improvements have been implemented following PSM audits in 1995 and 1998. Accordingly, the dates provided in Section 7. Prevention Program Level 3 represent the latest updates to the program elements. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: For our lone toxic chemical, chlorine, we have reviewed and adopt ed Chlorine Institute guidelines and advice regarding the safe storage and handling of chlorine. This includes personnel training as well as robust equipment designs. For flammables, we have adopted several API, NFPA, insurance company, ASME, ANSI, and other codes and standards. Our firewater system is currently undergoing a review and upgrade. Additional prevention steps continue to evolve as a result of on-going process hazard analyses. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: There have been no releases of chlorine or flammables at the Valero Houston Refinery in the past five years that have had an adverse impact on the community. There were two incidents at the facility that meet the EPA Risk Management Program (RMP) reporting requirements with respect to near misses; one for a release of chlorine, and one for a release of flammables. In August of 1998, a worker was tightening connections on a chlorine flow measurement device when a small leak occurred. The employee quickly stopped the leak by closing a valve, but he was exposed to a small amount of chlorine when his respirator was improperly sealed. As a result of this incident, Valero has improved personnel training and has introduced changes to the protective equipment our em ployees wear when working around chlorine. The employee experienced only a minor irritation. In June of 1995, a rod pushes through the cylinder of a hydrogen compressor in the Platformer unit. Operators noted a loud knocking preceeding the incident and were taking action when the failure occurred. Following the event, replacement of the compressor and its spare was implemented. Modifications in maintenance procedures, changes to the breaker system, and other corrective actions were introduced. For the above incident, and for others that do not meet EPA's definition, we have conducted formal incident investigations to identify and correct the identified causes of the events. 6 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan through Channel Industries Mutal Aid and the Houston Fire Department. 7 PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: Additional equipment, including: - emergency response air supply equipment - a new, quick attack truck - upgrades to fire fighting apparatus - increases in the strength (numbers) of the emergency response team. 8 CERTIFICATIONS Within the past five years, the processes have had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). Additional measures have been listed above, intended to prevent or mitigate potential offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process es, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Signature Ralph Youngblood Title Vice President Refining Houston Date June 20, 1999 |